Question

Mr. Santos, a resident of the Philippines, entered into a contract with Ms. Lee, a resident of South Korea, for the sale of a property located in Japan. The contract did not specify the governing law applicable to the transaction. However, a dispute arose concerning the performance of the contract and the parties are now seeking legal resolution.

In determining the applicable law to resolve the dispute, the court needs to consider the doctrine of Lex Loci Solutionis. Under this doctrine, the law of the place where the contract is performed governs the rights and obligations of the parties.

Discuss the following issues:

1. Explain the concept of Lex Loci Solutionis and its purpose in determining the applicable law in contractual disputes.
2. Apply the doctrine of Lex Loci Solutionis to the scenario provided and determine the governing law in resolving the dispute between Mr. Santos and Ms. Lee.
3. Discuss any exceptions or limitations to the application of Lex Loci Solutionis in contractual disputes.